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NY 893101




January 6, 1994

CLA-2-42:S:N:N6:341 893101

CATEGORY: CLASSIFICATION

TARIFF NO.: 4202.92.4500

Mr. David A. Eisen
Siegel, Mandell & Davidson, P.C.
Counselors At Law
One Astor Plaza
1515 Broadway - 43rd FL
New York, NY 10036-8901

RE: The tariff classification of a waist bag with a detachable wallet from China and/or Taiwan.

Dear Mr. Eisen:

In your letter dated December 9, 1993, on behalf of Avon Products, you requested a tariff classification ruling for a waist bag with a detachable wallet.

Item PP 118104 consists of a waist bag with a detachable trifold wallet. Both are manufactured of the same fabric which consists of a calendered compact plastic sheeting with a woven fabric backing. The waist pouch measures 9 inches in length, 7 inches in width and has a 1 1/2 inch gusset. There is a central storage compartment, one front change pocket with hook and loop closure, a large top flap closure with a zippered pocket and two zippered pockets sewn into the waist strap. There is a woven fabric snap tab affixed to the bag body beneath the flap closure. The wallet is trifold in design with a hook and loop closure. It has a billfold section, clearvue window and three credit card slots. There is a woven fabric loop approximately 1 1/2 inches long sewn to the back of the wallet. The wallet can be affixed beneath the waist bag flap by means of the rear loop and snap tab. It is secured and easily accessible when carried under the flap. The snap tab permits easy removal of the wallet. Your sample is being returned as you requested.

The applicable subheading for Item PP 118104, the waist bag with a detachable trifold wallet of plastic sheeting, will be 4202.92.4500, Harmonized Tariff Schedule of the United States (HTS), which provides for travel, sports and similar bags, with outer surface of sheeting of plastic, other. The duty rate will be 20 percent ad valorem.

We have reviewed the various citations cited in your request. Although these decisions have ruled upon various travel bags and a wallet, no decision addresses a combination of a travel bag and wallet. The citations do not support your asserted classifications. If you disagree with this decision, we suggest you seek reconsideration as provided by CFR 177.2 (b)(C).

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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